Professional Documents
Culture Documents
Topic Page
Introduction
Cross-Contamination ................................................................................... 2 – 5
Uniforms ........................................................................................................ 2 – 6
Hair............................................................................................................ ................ 2 – 10
Jewelry ......................................................................................................... 2 – 11
Fingernails ................................................................................................... 2 – 12
Summary...................................................................................................... 2 – 28
There are three significant reasons for using good manufacturing practices
(GMPs) in all areas of your processing facilities:
1) Providing safe, high quality dairy products for the consumer makes good
business sense.
2) They are mandated by the Food and Drug Administration's Code of Federal
Regulations (CFR), specifically 21 CFR Part 110, GMPs.
3) They are mandated by the Wisconsin Department of Agriculture, Trade and
Consumer Protection's Administrative Code, specifically Chapter ATCP 80,
Dairy Plants.
All employees and visitors should be made aware of GMPs. Employee training is
critical for GMP compliance. Training new employees at the time of hire and
yearly thereafter is a guideline for effective training programs. To document
training, a signed statement indicating that employees have read the policies set
forth, they understand those policies, and they are willing to adhere to them is
necessary. This document is to be maintained by the HACCP coordinator.
There are many GMPs a company can implement. The degree to which these
are implemented is dependent upon the size, practicality and ability of the
company to bear the expenses of the GMPs. The GMP policy will represent and
be customized to your needs. The following practices are guidelines to consider
employing when developing a GMP policy.
Most of the day-to-day operational food safety rules in your plant are in place
because GMPs require them to be there. Maintaining constant awareness of food
safety and following proper procedures help contribute to a safe, high quality food
product you can be proud to produce.
Uniforms
Footwear, Footbaths and Footfoamers
Hair
Jewelry
Fingernails
Hand Washing, Hand Sanitation and Glove Use
Health Practices
Food, Drink, Candy, Gum, Cough Drops
Each of these GMP procedures and processes are covered in this manual.
Implementing these various GMP programs will provide the basis for building a
solid prerequisites program and create the foundation for developing and
implementing a HACCP-based food safety program.
Equipment: Equipment such as fork lifts, pallet jacks, carts and floor
cleaners that travel throughout the plant must be well maintained and
White uniforms for dairy plants are standard for production personnel.
A distinguishing color may be worn by management and maintenance
as described below. Laboratory coats, smocks or plastic disposable
aprons are recommended for all management personnel or plant
visitors.
Ideally, uniforms should not leave the facility except for cleaning. If
employees take uniforms home, a policy of not touching pets or doing
yard or farm work while in uniform before reporting to work should be
initiated. In this manner, animal hair, dander, dirt, bacteria and other
potential cross-contamination sources will be minimized.
A clean uniform should be worn at the start of each production day and
placed in a designated “used uniform” container at the end of
production. Used uniforms should be handled properly so they do not
become a source of contamination.
Items placed in shirt pockets may fall into product when bending over.
To avoid the temptation of putting items in pockets, uniforms should
not contain pockets above the waist. If uniforms contain top pockets,
it is recommended to sew these pockets shut.
Employees should change into their work clothes and footwear upon
arriving at work.
Clothing should remain at work or be taken home for cleani ng, if the
company does not provide such service.
A policy of not touching pets or doing yard or farm work while in work
clothes before reporting to work should be implemented. In this
manner, animal hair, dander, dirt, bacteria and other potential cross-
contamination sources brought into the plant will be minimized.
Dairy plant personnel may live on farms. The farm environment can
introduce numerous contaminants to clothing such as animal hair,
bacteria, and soil. These employees must be trained regarding the
hazards that can be introduced to the production facility if locker rooms
are not provided and they change at home. If animals are contacted
before coming to work, a shower and complete change of outside
clothing and footwear is necessary.
Light colored clothing should be worn because it will show dirt more
clearly, initiating a change or washing of clothing.
No tank tops should be worn. Tank tops do not cover the worker
properly and do not protect food and equipment from sweat and hair.
For employee and visitor safety, open toed footwear or sandals should
be prohibited.
They do not protect against hot liquids, acids, and caustics used in the
facility.
Such footwear does not protect the facility from contamination from
feet.
If the footwear does not have slip resistant soles, water, oil, some
sanitizers and product residues on floors may cause an employee to
fall.
Footbaths/Footfoamers:
Step into the footbath so that the sole and arch on footwear come in
contact with the sanitizer. The sanitizer will not damage footwear.
Hair
Hairnets and beard snoods should be kept at all production entrances allowing
easy access by all employees and visitors.
Hairnets are to cover the entire head (front, back and sides) and
include all hair: Often bangs or hair in back of the head is excluded
from coverage within the hairnet. This practice should be avoided.
All employees in production, packaging or other plant areas should
be trained on proper hairnet usage:
Trimmed mustaches should not fall below the lower lip or extend past
the edge of the mouth.
Jewelry
Plain wedding bands without grooves may be worn. For those who
cannot physically remove rings, gloves should be worn.
If employees have rings that are not removed easily, they should wear
gloves. Gloves prevent dirt and product from accumulating within
hard to clean grooves within rings. They also help to prevent rings
catching on equipment causing employee injury.
Any medical alert tags should be documented at the start and end of
the shift and if they cannot be accounted for, management should be
notified for potential placement of product on hold.
Fingernails
Recent scientific studies have proven that fingernails are a common source of
contamination. Dirt and bacteria build up underneath fingernails. The longer the
fingernails, the greater the concentration of dirt and bacteria. Men and women
both should keep their fingernails short (no longer than 1/8 inch) to help minimize
bacterial contamination.
Polish or decals may chip off and fall into the product and may lead to
bacterial or physical contamination.
Therefore, when a person touches food, any bacteria on the skin may be
transferred. People who eat that food may become ill and in some cases die
depending on the type of bacteria that are transferred (cross-contamination). To
avoid cross-contamination, proper hand washing is essential. Glove use is
strongly recommended when touching finished products that are not yet
packaged.
It is important to remember that gloves are meant to protect the food from
the employee and not protect the employee from the product. Because
hands can easily transfer pathogens, it is necessary to properly wash and
sanitize hands:
After any absence from the work area or any other reason
for leaving the workstation.
Change gloves more frequently or to avoid sweat build up, wear cotton
liners.
Provide gloves that are colors such as purple, red, blue or green. If
gloves tear and fall into the product the clear glove parts will be difficult
to see. Colored gloves will be more easily seen when damaged.
Health Practices
Employee health and hygiene, directly or indirectly, are important aspects of food
safety and sanitation. Sick employees and poor hygienic practices rank second
among the causes of foodborne illnesses.
Injuries on the hands and the lower portions of the arms such as cuts,
abrasions, burns and even a hangnail must be cleaned and treated
immediately. Often these injuries become infected, and as a result,
can contribute to the potential contamination of food and equipment
with disease causing bacteria.
Never clear a drain with a pressure hose. This may create an aerosol
of drain contents into the surrounding environment and increase the
opportunity for pathogen contamination.
Hoses should be stored properly with nozzle or end opening off the
floor when not in use.
All utensils and other items that come in contact with product
containing an allergen [see allergen listings in HACCP Program
section on allergens] must be labeled and designated for use only with
that allergen-containi ng product unless thoroughly cleaned after each
use and sanitized before each use.
Hard bristle brushes and green scrub pads will scratch stainless steel
surfaces. Microorganisms may become embedded in the scratched
areas. A biofilm could form which is an invisible matrix of
microorganisms embedded in protein, fat, minerals and
carbohydrates. It may not be easily removed from a surface.
Scratches in stainless steel create an opportune surface in which
biofilms can form. It is known that some sanitizers may not be
effective against killing microorganisms embedded in biofilms.
Never use steel wool; hard bristled brushes, or green scratch pads in
food processing plants. They scratch equipment leading to crevices
in which bacteria and product residue can become lodged, resulting in
contamination. Green scratch pads may contribute physical
contamination to foods [they have a history of pieces falling off].
All brushes and pails should be color-coded and used only for their
intended purposes. Below are examples of industry-recognized color
coding schemes:
All employees should assist in keeping the plant clean and well maintained.
Cleanliness is a reflection on the plant and the employee’s commitment.
Plant grounds, parking lots, and loading docks should be free from
litter and clutter.
Trash should be contained in one area, kept covered, and cleared from
under and around dumpster areas.
Pallets should not be stored outside. They are a vehicle for entry of
pests and pest excrement into the plant. If pallets are stored outside,
they must be inspected and cleaned before use.
In processing areas:
Remove any litter when present and immediately clean up any spills.
Good lighting is necessary for both the safety of the employee and for
the product [reference requirements in ATCP 80.08(5)].
Processing plant and storage structures must have roofs that are free
from leaks. Leaks can result in damaged products, bacterial
contamination and residues from bird droppings.
Drains from air cooling units should go directly to a floor drain. These
air cooling units must be maintained to keep the drain open to prevent
the pan from overflowing.
Ideally, air should flow from higher pressure finished product areas to
lower pressure raw products areas to avoid cross-contamination.
If air intakes are located on the roof, remove bird nests and other
contamination sources from the area. Watch for standing water that
may harbor bacteria and encourage bird activity.
Ideally, air filters for critical areas should be of the HEPA type.
Below are ways employees can help control insect and rodent
infestation:
Keep all doors closed and make sure that they are tight fitti ng. Notify
your supervisor if a door does not close tightly.
Always keep storage areas clean and free of clutter and dust to reduce the risk of
microbial contamination and insect/rodent harborage.
Always follow First In – First Out (FIFO) procedures for materials and
ingredients:
Always properly label, seal, and date containers of all partially used
ingredients and packaging materials:
All pails should be labeled with their contents and the date the pail was
received. If ingredients are transferred or separated into smaller
amounts, each individual container should be labeled appropriately.
Clean all raw material containers on the outside before they are
brought into processing areas.
Store all ingredients and packaging material off the floor on pallets in
good repair. Do not store supplies directly on the floor. This
includes intermediate containers for ingredients such as jugs, pails or
other items used to transport ingredients. Use plastic pallets that
are in good repair:
Store all ingredients, packaging material and other supplies off the
floor to prevent contents from becoming wet, soiled, damaged, or
contaminated.
Plant Chemicals
Recent national events have heightened the need for increased bio-security
measures. To avoid the potential for chemicals to contaminate the food supply,
increased chemical security is necessary.
All employees should receive trai ning in chemical handling and safety.
Process Control
During the food production process, there are numerous activities done that help
to reduce introduction of hazards. Examples of control steps are given below:
Each plant should have a policy not to receive items into inventory in
which the package is damaged to the extent that the item is exposed.
Prepare any liquid slurry just before use. This helps to maintain lower
slurry temperatures which will minimize microbial growth and toxin
production.
Summary
GMPs are often the hardest policies to enforce. Changing the habits of
employees takes constant management supervision. It is often the GMPs that
are the cause of audit deficiencies. Therefore, education and leadership by
management can help employees become aware of their role and how to correctly
follow the policies. It is important for employees to communicate with their
supervisors/managers when they see a need to improve or modify the GMP policy.
Each plant will have a good manufacturing practice policy that is unique and
specific to the activities within that plant. The policy should be tailored to the
company, its needs, and its history. All employees including managers, office
personnel, maintenance and production personnel must follow the good
manufacturing practices to insure effective operation of the plant. Visitors and
outside contractors must also be included in all GMP practices for total
effectiveness.